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#2050218 - 11/18/15 02:09 PM BSA/CIP
LauraC Offline
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Joined: May 2015
Posts: 17
New Jersey
If there is an address discrepancy in a loan file (drivers license has a different address from the subject property which is owner occupied) and the lender documents occupancy sufficiently through a letter of explanations, Fraud Guard, or other documentary items, is it required for the lender to also include a summary of how the issue was cleared if the documentation speaks for itself? Can anyone reference a regulation requiring, or not requiring this extra step?

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BSA/AML/CIP/OFAC Forum
#2050224 - 11/18/15 02:32 PM Re: BSA/CIP LauraC
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,649
Galveston, TX
31 CFR 1020.200(a):

(3) Recordkeeping. The CIP must include procedures for making and maintaining a record of all information obtained under the procedures implementing paragraph (a) of this section.

(i) Required records. At a minimum, the record must include:

(D) A description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained.

Whatever you feel meets this requirement is what you keep in the file.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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